Water hungry Burning ’s water to produce electricity

“Among the many things that I learnt as president was the centrality of water in the social, political and economic affairs of the country, the continent and the world.” Nelson Mandela, World Summit on Sustainable Development, Johannesburg, 2002 Report 2012 © Greenpeace / Oswald Chikosi 2011. For more information contact: [email protected]

Lead author: Melita Steele

Contributing author: Nina Schulz

Edited by: Fiona Musana, Nina Schulz

Acknowledgements: Lauri Myllyvirta, David Santillo, Sanjiv Gopal, Olivia Langhoff, Ferrial Adam, Ruth Mhlanga, Michael Baillie, Mbong Akiy

Published in October 2012 Greenpeace Africa 10A and 10B Clamart House, Clamart Road, Richmond Johannesburg, South Africa

Postal Address: Greenpeace Africa PostNet Suite 125 Private Bag X09, Melville Johannesburg, 2109 South Africa Tel: +27 (0)11 482 4696 Fax: +27 (0)11 482 8157 Website: www.greenpeaceafrica.org

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Executive Summary 3 1. Background 6 1.1. Water scarcity 6 1.2. Looming conflicts over water 7 1.3. Climate Change 8 1.4. Making the coal-water connection 8 1.5. Water: the foundation of life 10 1.6. Coal versus water as a strategic resource 12 2. The thirsty, polluting coal process 13 2.1. The water impacts of coal production 13 2.2. The water impacts of coal combustion at coal-fired power stations 14 2.3. Water contamination by Acid Mine Drainage 15 3. ’s “efficiency” efforts 18 3.1. Eskom’s thirst for water: incremental efficiency and pollution reduction measures 18 4. Who really controls the water? 20 4.1. Water and the electricity sector 20 4.2. Transparency and water licences: the litmus test for democracy? 20 4.3. Extreme water supply options: water transfer schemes and desalination 21 5. Greenwashing: Eskom’s renewable energy efforts 24 6. The solution to South Africa’s water and electricity crisis: An Energy [R]evolution 25 7. Conclusion 27 8. Greenpeace recommendations 28 9. References 30

2 Water hungry coal: Burning South Africa’s water to produce electricity Executive Summary

Safe, affordable and accessible water is regarded as one of resources at severe risk. It is very likely that building more our planet’s scarcest natural resources.1 This is particularly coal-fired power stations like Medupi and Kusile, and true on the African continent, where water insecurity is often increasing coal mining to supply them will essentially send an everyday reality. At the same time, equitable access to South Africa into a water deficit, given that the country’s water is fundamental to life and human health and well- total available water resources may well have already been being. allocated to the maximum.78

South Africa already struggles with water scarcity, and it Coal-fired electricity generation currently contributes to over is predicted that the country will face a significant water 90% of South Africa’s electricity,9 with Eskom accounting for crisis in the coming decade.2 Thus water scarcity could a staggering 62.3%10 of South Africa’s emissions in 2011.11 well become a fundamental development constraint in the Burning coal to produce electricity is an incredibly water future.3 Within this context, a range of choices are being intensive process,12 with a number of serious implications made. Choices with major implications for water availability, for both water quantity and quality.13 Coal-fired power poverty alleviation, job creation, electricity generation and stations use significantly more water compared to the water energy access. One of these choices relates to the energy needed for most almost ‘water-free’ renewable energy future of this country, which has economy-wide implications. technologies.14

The South African government and Eskom are making Eskom itself admits that in the process of generating a clear energy choice at the moment: in favour of coal electricity, the utility is a significant user of the country’s expansion, at the expense of access to scarce water fresh water.15 In one second, Eskom uses the same amount resources, people’s health and affordable electricity. The of water as a single person would use within one year, based coal mining and electricity industry contribute substantially on access to the minimum 25 litres of water per day. And in to water pollution and scarcity, jeopardising the country’s seven seconds, the utility uses nearly the same amount of ability to deal with an impending water crisis. Tragically, water as a household would use in an entire year, based on competition for this scarce resource may well culminate in the free basic water allocation.i Within this context, in 2012 conflicts over water. This means that the linkages between there are still nearly a million households without access to coal-fired electricity generation and water can no longer be the minimum 25 litres of water16 per person per day.17 ignored.4 According to the National Water Act (Act no. 36 of 1998) However, the country continues to try to solve the symptoms the government, as trustee of the nation’s water resources, of these crises instead of addressing the causes. Eskom must allocate water equitably, and in the public interest.18 and the South African government continue to deal with These allocation decisions are becoming ever more crucial the electricity crisis by building new coal-fired power against the backdrop of an impending water crisis, which stations, pushing the price of electricity upwards due to rising coal costs,5 generating substantial environmental and health impacts, worsening climate change, and thereby i During 2011, Eskom used 327 billion litres of fresh water, amounting to a staggering 10 000 litres of water per second, compared to a single person using the accelerating impacts on water scarcity. And the moves to minimum of 25 litres of water per day, which would amount to 9 125 litres of water per label coal ‘a strategic resource’6 puts South Africa’s water year or a household using the minimum 6 000 litres of water per month, which would amount to 72 000 litres of water per year. © Greenpeace / Paul Langrock 2012.

Water hungry coal: Burning South Africa’s water to produce electricity 3 makes transparency and accountability in the water sector country: to half of what would be required for coal mining even more important. However, there is a serious lack of and coal power combined, and to a level even lower than transparency regarding water management plans and water a 2007 baseline.ii By shifting away from coal and nuclear licences in South Africa. Most of this information remains energy and towards renewable energy systems, substantial confidential, and inaccessible to the public. amounts of scarce water could be saved, and diverted to other sectors where it is urgently needed, avoiding water Of the 22 mines that supply Eskom with coal, half were insecurity and potential conflict.29 operating without a valid water licence in 2010,19 which creates clear threats to the accountability of users and the Eskom is the only recognised ‘strategic water user’ of protection of this country’s water resources.20 And there national importance in South Africa.30 But the utility’s are still more questions than answers. A recent inquiry by unnecessary water-use for its coal-fired power stations Greenpeace Africa shows that in 2012 the Department of will push this country closer to a water crisis. The utility Water Affairs has issued 83 water licences for coal mining, consistently makes seemingly convincing public statements while the Department of Mineral Resources lists 119 about how it takes concerns about its water use and operational coal mines.21 The Department of Water Affairs environmental sustainability ‘seriously’.31 However, Eskom did not provide an answer clarifying this gap in licensing by simply continues to prioritise coal to the exclusion of all the time of publication of this report. other options. And the ‘solutions’ the utility proposes are not solutions at all, they are simply expensive technology-fixes South Africans have a right to know how water is being designed to maintain the status quo. allocated, managed and polluted. Confidentiality in the water sector essentially disempowers the people of this In light of global water scarcity and catastrophic climate country, effectively removing their ability to hold industry change, incremental improvements in the technology used accountable for its water use. This is particularly true given to burn coal to create electricity are simply not good enough. the fact that no part of the country’s water resources are In reality, Eskom has failed to recognise that the way it regarded as ‘private property’,22 and the National Water currently generates, transmits and distributes electricity is Act (Act no.36 of 1998) clearly states in its preamble that flawed and unsustainable, with substantial, unavoidable and “water is a natural resource that belongs to all people”.23 long-lasting impacts. The connection that is not being made The current allocation of water to the coal mining industry is that reducing the country’s coal addiction may actually and to Eskom for coal-fired electricity is not a transparent, help to cultivate economic growth and create sustainable accountable or sustainable decision. And it is definitely not jobs through renewable energy.32 in the public interest, given that there are very effective alternatives to coal, but there are no alternatives to It is often argued that South Africa’s significant coal water. dependency results in a number of serious ‘environmental’ impacts.33 However, it is easy to dismiss these impacts as The vast majority of renewable technologies use ‘environmental’ in nature. Although the right to have access substantially lower amounts of water than coal-fired to an environment that is not harmful to people’s health electricity generation.24 25 Wind and solar photovoltaics (PV) or well-being is enshrined in the country’s constitution,34 are virtually ‘water-free’ technologies.26 Not considering ‘environmental impacts’ are often viewed as a necessary these alternatives is economically irresponsible, given the evil to allow for development, job creation and a stronger high opportunity costs. In fact, investing in another new economy. The reality, however, is that it is impossible coal-fired power station (Kusile) equates to a hidden cost to survive without water, and all South Africans have of an estimated R42 billion per year that it would operate an inalienable right of access to sufficient, clean, safe - and this is only taking into account the water use of the drinking water.35 The country’s coal dependency is a clear power station.27 At the high end, the estimated total social illustration of how decisions made today can have long-term damage cost (or externality cost) of Kusile is economically unintended consequences. very significant, and could amount to R60.6 billion per year that it operates.28 A significant water crisis is looming in South Africa,36 and investing in new coal-fired power stations instead of The real solution to South Africa’s water and renewable energy and energy efficiency puts all South electricity crisis is not incremental improvements Africans at risk. Water is not just an environmental issue. in coal technology, it is an Energy [R]evolution: It is a fundamental issue at the very heart of justice, a shift away from coal and nuclear energy, and development, economics and human rights. towards renewable energy and energy efficiency. This report finds that implementing an Energy

[R]evolution in South Africa would not only deliver sustainable ii These calculations are based on a comparison of water usage for two scenarios electricity to all citizens, but would drastically decrease the in 2030 (compared to a 2007 baseline): The Reference Scenario (modelled on the IRP2010 scenario) and Greenpeace’s Advanced Energy [R]evolution scenario, see p. 25 amount of water required for electricity production in the of this report.

4 Water hungry coal: Burning South Africa’s water to produce electricity Water SouthAfrica’s hungrycoal:Burning watertoproduce electricity 5

© Greenpeace / Oswald Chikosi 2011. 1. Background

There are few issues that are so deeply inter-related and development constraint”, not only for this country, but for the important for development as the issues of energy and entire SADC region.49 water.37 Water plays a critical role in poverty alleviation and development.38 But at the moment, we are essentially South Africa has a history of trying to solve water scarcity burning our rivers to produce electricity.39 Fundamental problems by engineering dams and ‘importing’ water changes are needed in South Africa’s water and energy through inter-basin transfer schemes, but this is not a long- sector in order to meet the challenges posed by water term solution to water scarcity. In fact, this kind of technical scarcity, and to ensure universal, equitable access to water response often comes with dramatic consequences, in this country.40 Making the connection between water and including the loss of ecological integrity in aquatic systems is clearly a very important step - indeed, and increased levels of pollution from mining.50 In the the linkages between energy, electricity generation and preamble of the National Water Act (Act no. 36 of 1998) it is water can no longer be ignored.41 This report substantiates recognised that “water is a scarce and unevenly distributed these underlying linkages, and the impacts of short-sighted national resource”.51 Water has to be transported over coal-based energy and electricity generation choices on large distances to supply urban areas,52 and this means South Africa’s water. that millions of South Africans already drink water that was captured in reservoirs in excess of 400km away.53

1.1. Water scarcity That water scarcity is a significant challenge for South Africa, is something even the Department of Water Affairs Throughout its history, the provision of an adequate acknowledges. The Department itself has projected that supply of water has been one of the key limiting factors water demand will exceed supply by 2025, even by its most in the economic development of this country,42 and key conservative scenario, unless considerable attention is paid issues around equity and access to water remain. This is to managing water demand.54 55 Although substantial steps addressed in the preamble of the National Water Act (Act forward have been taken, the delivery of water continues to no. 36 of 1998): “Recognising that while water is a natural be difficult. Despite the fact that Section 27 of South Africa’s resource that belongs to all people, the discriminatory laws constitution enshrines the basic human right of access to and practices of the past have prevented equal access to sufficient, safe, reliable water,56 in 2012 there are still nearly water, and use of water resources”.43 a million households without access to the minimum 25 litres of water per person per day.57 58 59 South Africa has insufficient and unreliable rainfall,44 which means that it is a net importer of water.45 46 The country The Water Services Act (Act no. 108 of 1997) enacted this has a mean annual precipitation of 497mm/year, which right to access water, by stating that no water authority is almost 50% less than the global average of 860mm/ may refuse to give people within its jurisdiction access year.47 In fact, all three of the most economically developed to water services.60 The current Basic Free Water Policy countries in the Southern African Development Community makes provision for 6000 litres of water per month for (SADC) - Botswana, South Africa and Namibia - are water each household, free of charge.61 62 But equity around scarce.48 This means that “water scarcity is a fundamental water also includes the quality of access to water: in 2010 © Greenpeace / Jennifer Bruce 2012.

6 Water hungry coal: Burning South Africa’s water to produce electricity the Department of Water Affairs estimated that there are poor quality of life are resulting in increased service delivery a further two million people who have access to a water protests - often linked to limited access to water, homes supply that does not meet the basic services standard.63 and electricity.76 In fact, according to the Water Research South Africa is facing a serious water supply crisis:64 it is Commission, water scarcity may already be driving service estimated that the country’s population will grow to nearly delivery protests in South Africa,77 and the Minister of Water 53 million people by 2025,65 and this is likely to amplify the Affairs has acknowledged that there is a “growing and already-existing competition between the needs of different disturbing trend of service delivery protests and water tends water users.66 Combined, these factors are likely to create to be a common denominator for most of these”.78 a significant and increasing strain on the country’s water supply. In the words of a member of the Muyexe village in Limpopo: “How can a person survive without water? It is an essential However, it is not only the availability of water that is a source of life. Even if people want to develop their land, due constraint, but also its allocation.67 The National Water Act to water scarcity it cannot happen…”79 However, inequitable (Act no. 36 of 1998) affirms that water is a common good access to water is a daily reality for millions of South Africans and that the State is the custodian of this scarce natural - for the residents of Pelhindaba, there are 10 communal resource.68 Thus, ownership of South Africa’s water is taps to serve a population of more than 600 people, but only replaced by the right to its use.69 The Act makes it clear two of these taps were actually in working order in 2012.80 that water must be allocated taking into account the three It is therefore unsurprising that the government is blamed key principles of equity, beneficial use and sustainability.70 for failing to deliver services to communities around the According to the Act, the government, as trustee of the country.81 nation’s water resources, must act in the public interest to ensure that water is used, protected, developed, conserved, managed and controlled in a sustainable A river basin divided and equitable way for the benefit of all South Africans.71 But these allocation decisions are becoming ever more The Steelpoort River Basin flows into the Olifants River. complex against the backdrop of an impending water crisis, In this basin, water users already perceive there to be a and even the Department of Water Affairs acknowledges number of problems related to the quality and quantity that “water allocation challenges are a reality”.72 This makes of water, which can lead to tension and conflict. The transparency and accountability in the water sector of people living in the river basin also lack the information critical importance. related to the water consumption of other water users, which reduces transparency and accountability, and can easily lead to increased tensions during periods 1.2 Looming conflicts over water of scarcity. In this region, farmers and communities already come into conflict with mines due to over-use In semi-arid countries such as South Africa, water scarcity and pollution of the water resources. If there are water- is a critical stressor, which can determine livelihood related conflicts, the users go to court (if they are able vulnerability, and the impacts of water insecurity can to afford this), but this obviously puts marginalised produce serious stress at all levels.iii73 In the future, the communities at a disadvantage. competition for water is only likely to increase among water- intensive sectors such as agriculture, power generation At the moment, the Department of Water Affairs and the residential sector.74 Possibly creating unparalleled authorises the trade of water rights from farms to conditions for conflicts over water rights, and access to this mines in the area on a small-scale basis. However, the scarce resource. government will soon need to make decisions about whether mines should be given priority access to water, The second draft National Water Resource Strategy or whether some farming activities must be retained. recognises that increased water scarcity is likely to In a province that is rapidly becoming industrialised, increase competition between business and local this is going to prove to be a very difficult political communities (particularly poor and historically marginalised choice,82 with potentially significant impacts on people’s communities) in the future. And this potential competition livelihoods and food security. And this type of choice is could well result in conflict over water,75 with the poorest at echoed across the country. a clear disadvantage over well resourced big businesses. At the same time, many people living in informal rural and urban parts of the country still lack access to safe and South Africa has already allocated approximately 98% of adequate drinking water. This means that water scarcity and the national water resource.83 84 This is an enormously high insecurity, and unsatisfactory delivery of services combined allocation figure, which means that the country has no with factors such as poverty, inequality, unemployment and remaining buffer or dilution capacity for times of drought, or future economic growth,85 or even to deal with future water conflicts. The decision to invest in new coal-fired power stations iii Village, local municipality, district municipality and nationally.

Water hungry coal: Burning South Africa’s water to produce electricity 7 instead of relatively ‘water-free’ technologies such as wind the demands of energy-intensive industry. Clearly, achieving and solar photovoltaics (PV) has substantial implications for universal electricity access for all South Africans “does not South Africa’s water security, and threatens the availability and justify the building of large coal-fired power stations”.102 quality of the scarce resource. This decision is clearly not in the public interest. As the country’s only ‘strategic water user’, the It is undeniable that significant contributions are made to Department of Water Affairs guarantees Eskom’s water supply, the South African economy through the mining and primary come ‘hell or high water’86 - potentially at the expense of other minerals industries. However, the development pathway users in times of drought. But there is a lack of transparency South Africa has chosen does not come without a price: around how this allocation of water is made, what the costs the country is a significant emitter of greenhouse gases, are of prioritising Eskom’s water-intensive coal-fired power it has an energy intensity that is significantly higher than stations, and why Eskom is not being pressured to shift towards average,103 and Eskom uses slightly more than a staggering renewable energy. 10 000 litres of water per second.104 In addition, while the South African government might argue that the country is still developing and needs to cultivate rapid economic growth to 1.3. Climate Change create employment and overcome poverty, the reality that the country’s carbon emissions per capita are way above Global climate change has very specific implications for the global average, and will need to fall significantly, still South Africa, and is likely to reduce Southern Africa’s needs to be confronted.105 water resources even further.87 88 The government’s Water for Growth and Development Framework accepts that Building new coal-fired power plants will increase the climate change is a threat to the sustainability of water country’s emissions, accelerate climate change and worsen supplies, and that it has the potential to significantly affect already existing water insecurity. This in itself will create the availability of water in South Africa.89 Climate change is fundamental future development constraints, with impacts predicted to result in more extreme and variable weather on food security, industrial development, water access and events (droughts and floods) in many parts of the country, water rights. Clearly, the deeper causes of water scarcity which will significantly impact on river flows and water and the electricity crisis need to be addressed. However, availability.90 91 The region is likely to experience substantial the connection that reducing the country’s coal addiction reductions in maize production and it is estimated that by may actually help to cultivate economic growth and create 2020, yields from rain-fed agriculture in the region could fall sustainable jobs through renewable energy is not yet being by up to 50%.92 It is also likely that temperature impacts will made.106 increase crop water requirements.93 At the moment, there are 13 operational coal-fired power stations in the country,107 and these stations use 1.4. Making the coal-water connection conventional pulverised coal technology. The quality of coal used is poor, with a high ash content,108 and low calorific South Africa is a significant producer, user and exporter of values, which translates into high levels of pollution.109 coal, and the country’s economy is hugely dependent on Three retired coal-fired power stations have been brought coal.94 An estimated 93% of the country’s electricity comes back online (Camden, Grootvlei and Komati) to help meet from coal,95 and the carbon-intensive nature of Eskom’s rising demand. In addition, Eskom is currently constructing electricity production is reflected by the fact that in 2011, two new coal fired power stations: the 4 764MW Medupi Eskom contributed 62.3% of South Africa’s total emissions.96 plant in the Waterberg (to be supplied with coal by Exxaro), 97 In fact, Eskom emitted more carbon dioxide (CO2) in 2011 and the 4 800MW Kusile plant in (to be supplied than Sweden, Norway, Finland, Switzerland and Denmarkiv mainly by Anglo Coal’s New Largo colliery).110 combined.98 These new power stations, which will use supercritical Eskom claims that building new coal-fired power stations technology, will be the third and fourth largest coal-fired is necessary to meet ‘rising electricity demand in South power stations in the world,111 and Kusile will require a Africa’.99 In reality, investments in coal have failed to deliver massive 17 million tons of coal per year.112 Medupi, situated a secure supply of electricity to more than 12 million South in the remote Waterberg coalfields, will not initially use Flue Africans,100 and it is estimated that the electrification of Gas Desulphurisation (FGD) technology to reduce sulphur the country’s low-income households would actually “only emissions.113 In theory this means that Medupi will be increase electricity consumption by 0.11% in 2020”.101 This retrofitted with the technology. However, whether this in fact means that Medupi and Kusile are not being built to achieve materialises is another question - retrofitting rarely works electricity access for the poor,v they are being built to meet in practice as it is often difficult to implement and enforce retroactively, and usually has major cost implications.114

iv Eskom emitted a total of 230Mt of carbon dioxide (CO2) in 2011. CO2 emissions On the other hand, Kusile, located in Mpumalanga, will in Mt of CO by Denmark (46.78), Finland (55.01), Norway (37.31), Switzerland (42.42) 2 use FGD technology as soon as it is fully operational. Both and Sweden (41.71) come to a total of 223.23Mt of CO2. power stations will be ‘carbon capture ready’, which means v In fact, the “projected demand from all poor households in 2020 is expected to account for just 4% of the total electricity from the ”. (Tait and that they could potentially be retrofitted with Carbon Capture 115 Winkler. 2012). and Storage (CCS) technology at a later stage. But the

8 Water hungry coal: Burning South Africa’s water to produce electricity Map: the location of the Medupi and Kusile coal power plants currently under construction in South Africa.

GOOGLE MAPS - © 2012 GOOGLE

Water hungry coal: Burning South Africa’s water to produce electricity 9 reality is that CCS technology is largely unproven, it would 1.5. Water: the foundation of life use substantially more precious resources such as fresh water,116 would be hugely energy intensive and expensive, The Department of Water Affairs allocates significant and would not be ready in time to save the climate.117 amounts of water to the highly polluting electricity sector.130 Somehow, the linkages between how the intensive water- South Africa is a water scarce country, but every step in use for coal-fired electricity exacerbates water scarcity the chain of using coal to produce electricity pollutes and and water poverty, while also contributing to catastrophic consumes vast amounts of water.118 119 Together with coal climate change (which in turn will increase water insecurity), mining, burning coal for electricity generation has a number are not being made. Electricity is viewed as a “high-value of serious implications for both water quantity and quality,120 economic use of water”, which means that the allocation and it is undeniable that coal-fired electricity generation of water to Eskom’s power stations is considered to be of is highly water intensive compared to renewable energy strategic importance, and is prioritised. technologies such as wind and solar PV.121 South Africa is powered almost completely by coal-fired electricity and In light of growing water scarcity, the Department of Water according to current plans, the majority of the country’s Affairs has recommended dry-cooling technology at new electricity will be generated from coal-fired power for coal-fired power stations ‘where feasible’.131 Unfortunately, the foreseeable future, despite incremental increases this is an efficiency solution, which alone is ultimately short- in renewable energy.122 In fact, the Minister of Public sighted and useless; given the vital role water already plays Enterprises has publicly stated that South Africa might both during coal mining and coal-fired electricity generation. actually be looking to increase its coal expansion beyond The Department has fallen far short of demanding a transition Kusile by investing in a ‘Coal 3’ power station.123 to relatively ‘water free’ renewable energy technologies, which would be a much more valuable long-term solution, The limits to coal expansion are very real. Further large- with a much larger impact on preventing water insecurity scale development of South Africa’s coalfields is incredibly in South Africa.132 If the Department were serious about risky, particularly in the central basin, and could result in ensuring water availability through water conservation and permanent and expensive environmental damage. Indeed, demand management,133 there is no better way to manage unlimited coal expansion could put the quality of scarce the demand of the electricity sector than through a transition and essential water resources in this productive economic away from coal and towards renewable energy. region at risk.124 In the Waterberg area - where Medupi is under construction, and possibly where a third mega-coal The National Water Resource Strategy creates the fired power station may be built - there is an already severe implementation framework for the National Water Act (Act shortage of water.125 no. 36 of 1998) and Eskom is the only recognised strategic water user of national importance in this strategy.134 Therefore, the increasing number of new mega coal- This means that water transfers to supply Eskom are fired power stations will deal South Africa a triple blow: a supported by the Department of Water Affairs, and there is significantly larger contribution to climate change, greater a commitment to create a secure supply for the electricity pressure on already-stressed water resources126 and sector. In theory, higher water use priorities are accorded to increased health risks due to coal expansion.127 And if the water reserve, international agreements and obligations climate change continues as projected, coal-fired power and the water requirements for social needs,135 but there stations in drought-prone regions will increasingly become are clear trade-offs through prioritising water supply to even more of an unacceptable liability, locking the country Eskom. The utility requires substantial amounts of high into a dirty future that we can ill afford. quality water at the highest levels of assurance for its coal fired power stations: to provide steam for the turbines, to This means that the continued investment in new coal- cool and clean machinery and to scrub pollutants. During fired power stations fails to take into account the severity 2011, the utility used a staggering 327 billion litres of fresh of the water crisis facing South Africa or the size of coal’s water.136 However, the water use of the coal mining sector water footprint, while also totally disregarding the impacts that serves Eskom is not included in this calculation. The on people’s health. Instead, the investments in Medupi coal mining sector is not specifically included as a water and Kusile are creating a situation where, in addition user of strategic importance in the National Water Resource to significant greenhouse gas emissions, their water Strategy137 either. But Eskom relies entirely on the coal mines requirements will weigh even more heavily on already to supply their power stations, which indirectly includes the stressed water resources. This will lead to increased levels mines as strategic (and therefore prioritised) water users.138 of competition for scarce water with other key sectors such as industry, agriculture and domestic use.128 And while the government plans increased contributions from renewable energy,129 this increase is not ambitious enough to tackle the impending twin crises of water scarcity and unaffordable, inaccessible electricity.

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© Greenpeace / Jennifer Bruce 2012. © Greenpeace / Jennifer Bruce 2012. 11 1.6. Coal versus water as a strategic resource

Effective alternatives to coal-fired electricity exist, but there The allocation of South Africa’s key resources of water and are simply no alternatives for water.139 Efforts to declare coal coal are political decisions that will significantly determine a ‘strategic resource’,140 and thus further protect and expand the country’s future pathway. As outlined above and coal in South Africa are counter-intuitive, implying that coal acknowledged by the Department of Water Affairs and the will remain at the centre of the country’s economy for the National Planning Commission, water scarcity could well foreseeable future, despite the fact that the country’s coal become a future fundamental development constraint. reserves may well have been overestimated: South Africa If new coal-fired power stations are built, this will reduce may well have less coal than was once thought.141 Betting the availability and quality of South Africa’s water, create on coal is also in contradiction to the country’s move towards stranded assets in the form of coal-fired power stations a ‘low-carbon economy’.142 with limited or no water availability, while also accelerating climate change, which in turn will reduce water availability. Deciding which resources should be declared ‘strategic’ is This feedback loop has the potential to undermine electricity an enormous decision, that has many economy-wide, socio- generation and nullify attempts to increase access to political implications. One of the problems with declaring electricity. coal a strategic resource is that water and coal cannot be strategic resources at the same time. The coal mining and On the other hand, South Africa has some of the best electricity industry contribute substantially to water pollution renewable resources in the world, and renewable energy and scarcity, jeopardising the country’s ability to deal with technologies are able to deliver sustainable electricity, an impending water crisis. while at the same time substantially reducing the stress on South Africa’s water resources.145 Decades of investment Thus, the current allocation of water to these two sectors and technological progress means that renewable is simply not sustainable - neither in the short nor long energy technologies such as wind, solar photovoltaic term. Building new mega coal-fired power stations such as and solar thermal collectors are becoming steadily more Medupi and Kusile, and increasing coal mining to supply mainstream.146 In fact, between 2005 and 2010 the global them, is likely to send this country into a water deficit;143 installed capacity of wind grew by 333%,147 and solar given that South Africa’s water resources have already photovoltaics grew by more than 700%.148 essentially been allocated to the maximum.144 Labelling coal ‘a strategic resource’ puts the country’s water resources in The question remains: why are Eskom and the government severe danger, and locks this country into a dirty and risky not scaling up their ambition to tackle the twin crises of future. water scarcity and climate change? © Greenpeace / Oswald Chikosi 2011.

12 Water hungry coal: Burning South Africa’s water to produce electricity 2. The thirsty, polluting coal process

Every step in the coal chain requires direct use of water: the than in the underground mining process. This means that extraction and preparation of coal from mines, its incineration substantial amounts of water must be used for both dust at a coal-fired power station, the measures taken to control suppression and road wetting at the mines.152 153 dust and pollution at both mines and power stations, and the disposal of the coal combustion by-products.149 This Coal washing section will briefly outline the various stages of water use in the process of extracting coal and burning it to produce Before coal can be burnt at a coal-fired power station, it electricity. needs to be processed and cleaned. This means that the coal actually has to be washed, usually at the mines themselves.154 This water-intensive process separates 2.1. The water impacts of coal production impurities from the coal through a flotation process. Due to their greater density, the impurities sink to the bottom while Water depletion and pollution the coal floats freely.155 The use of groundwater during the coal washing process leads to the further depletion of this Coal mining has unavoidable impacts on local water resource.156 Washing coal creates substantial amounts of resources, both in terms of water consumption and pollution. contaminated ‘sludge’,vi 157 which must be disposed of in For both underground and surface mining, groundwater is slurry dams, vii and can pollute freshwater supplies if stored pumped out to dry the area being mined. As a result: flows incorrectly.158 of groundwater and streams are affected, water tables are lowered, ecosystems are damaged and entire regions Dirty water are put at risk. In some cases, water bodies have just disappeared.150 Any water that comes into contact with disturbed areas on the mine is known as ‘dirty water’ and is either used by Leachate from discard dumps, subsidence and discharges the beneficiation plant,viii used for dust control measures, of dirty mine water or Acid Mine Drainage from mining all pumped into slurry dams, or released into river systems. have a direct impact on water quality.151 Mining operations For all of these options, evaporation of water also occurs. need vast volumes of water for the following processes: Some mines re-use and recycle some of their water, which

Dust control measures vi A mixture of fine coal and water.

Large amounts of dust are created as coal is hauled along vii Slurry dams contain coal-combustion by-products. roads, and also results from stockpiles of coal and soil - dust viii Beneficiation is a mechanical process to improve the quality from surface mining is much more of a significant problem of coal prior to use. © Greenpeace / Graeme Williams 2008.

Water hungry coal: Burning South Africa’s water to produce electricity 13 means that different mines will have different water use disposal, drainage, sewage treatment and mine water figures, depending on the procedures used and the amount recovery.161 Water is also used in certain air pollution control of water that is recycled.159 measures (such as FGD), and is discharged into ash slurry dams, which contain coal ash.162 2.2. The water impacts of coal combustion at coal-fired power stations However, the majority of water is used in just two processes: the internal steam cycle and the cooling process.

Coal-fired power stations burn coal to produce either hot The internal steam cycle air or steam to turn the turbines so that they are able to generate electricity. Three fifths of the heat released from Figure 1 illustrates how water is used during the combustion coal combustion are lost as waste heat. Removal of this of coal to produce electricity. The process occurs as follows: waste heat through cooling consumes enormous quantities “demineralised water is piped above a boiler (2) where of water.160 the coal is burnt, and the heat turns the water to steam. The steam then turns a turbine (3) to generate electricity Water is used in the following processes in coal-fired power (4). As the steam passes through the turbine it is fed into stations: water purification, the steam cycle in generating a condenser (6), which transforms the steam back into electricity, cooling, sluicing of ash, ash handling and water”.163

Figure 1: Water use during the coal combustion process at a power station

The cooling process Air pollution control measures

All coal-fired power stations need a cooling process for Because burning coal to produce electricity is one of the power generation machinery as components can be most polluting practices on the planet, pollution control damaged by extreme heat.164 Water is used to condense measures are required. Substantial amounts of water are and cool steam165 - the cooling is necessary to condense needed for these processes: to handle and control the ash the steam after it has passed through the turbine, and to (a by-product of combustion), scrub out the sulphur released eject the excess heat into the environment. Cooling can in the flue gas, and also for CCS - should this technology be achieved using water, air or a combination of the two.166 ever become available. So-called ‘direct dry cooling’ technology keeps the cooling water in a separate closed circuit, which means that cooling happens through heat transfer rather than evaporation.167 Ironically, dry cooling does reduce water use, but is a less energy-efficient solution, and is also more expensive. Four coal-fired power stations currently use dry-cooling technology in South Africa168 and both Medupi and Kusile will use this technology.169

14 Water hungry coal: Burning South Africa’s water to produce electricity 2.3. Water contamination by Acid Mine Drainage

The issue of Acid Mine Drainage (AMD) is particularly oxygen.187 The mining process itself breaks up the rock alarming in South Africa’s semi-arid environment.170 The mass, bringing the iron-sulphide bearing rock into contact contamination of this country’s water through AMD is with water and oxygen. When these iron and sulphide-rich possibly one of the most serious and complex immediate minerals come into contact with oxygen and water they water quality/mining related problems.171 172 173 In fact, oxidise through a number of possible chemical pathways to the government’s Water for Growth and Development form sulphates, and thereby forms sulphuric acid as well as Framework identifies Acid Mine Drainage as an immediate iron oxides.188 189 crisis, which is a serious threat to water quality, and an obstacle to securing sufficient water for growth and The acidic water is then able to dissolve other minerals development.174 Indeed, Acid Mine Drainage presents in the rock, releasing aluminium and other toxic metals.190 a serious threat to both groundwater and surface water Both the presence of elevated concentrations of these resources in the Witwatersrand. If this threat is not properly metals and the high acidity (low pH) of the drainage water managed, it is estimated that per day, nearly 200 million itself, have negative consequences for aquatic ecosystems litres of AMD may pollute the area’s water resources, and “decreases the fitness of local water resources for use placing severe risks on the security of the water supply from by other users”.191 The drainage water can also seep into the Vaal River System.175 groundwater resources, as well as into streams and rivers a significant distance downstream from the source, with the Coal, copper and gold mining are all linked to the formation potential to acidify and contaminate soil, sediments and of Acid Mine Drainage.176 This report focuses primarily on water resources.192 In addition, depending on the nature the contribution of coal mining, which can have substantial of the mining activity and of the catchment, subsequent water impacts depending on whether the mines are working precipitation of iron-rich deposits (oxides and hydroxides), or abandoned, which mining methods are being used and of suspended sediments carried by the drainage and the geological conditions.177 Acid Mine Drainage can waters, can lead to siltation193 and physical impacts on originate from both operating and abandoned mine pits, but aquatic species.194 the AMD outflow into surface and groundwater resources can continue for decades after a mine has been abandoned. Within the context of natural weathering conditions, similar processes are produced, but at much slower rates, and the According to the Department of Mineral Resources, there acid that is produced is easily neutralised by the alkaline are 1647 active mines in 2012, with 119 operational coal materials found in the rock. Mining fast-tracks this process mines.178 However, in 2008, a total of 5 906 mines (across by comprehensively fragmenting the rock, quickly increasing all mining sectors) were considered abandoned, becoming the overall surface area for oxidation and acid dissolution the full responsibility of the government.179 The government processes.195 During opencast mining the rock mass is continues to be publicly criticised for not adequately deeply fragmented, which then maximises the contact tackling the issue of mine rehabilitation.180 Nonetheless, between water and rock. As a result, this type of mining can Mineral Resources Minister Susan Shabangu has stated be one of the most acid producing mining methods in areas that no mine rehabilitation had been carried out from 2010 in which the geology is rich in sulphides, though drainage to 2012, and that, shockingly, none was planned.181 These from sub-surface mines can also be highly significant and abandoned mines pose a major and specific threat to long-term.196 This acidic water then seeps into groundwater water quality. They are creating a marked deterioration of resources, and ultimately into streams and rivers acidifying groundwater quality as the workings become flooded and both soil and water resources.197 start to decant, producing highly contaminated AMD outflow with unacceptably high levels of heavy metals.182 183 And the The impacts of Acid Mine Drainage lack of urgent action to clean up these mines may well be “leading to an ecological and environmental disaster”.184 The impacts of AMD can be severe and long-lasting, requiring substantial (and expensive) interventions to How Acid Mine Drainage is formed reduce the impacts. It is clear that the contamination of major river systems (such as the Vaal) by AMD threatens Acid Mine Drainage creates three interrelated problems: it South Africa’s water security. A number of studies have creates water with a low pH, this acid water mobilises heavy predicted that AMD may entirely decant into the central metals from the environment, and treating the contaminated basin within the next few years, presenting a potential water with calcium to raise the pH creates saline water, environmental catastrophe, but also seriously threatening which needs to be treated through reverse osmosis or other the Johannesburg City Centre.198 However, finding the comparable processes.185 correct solution is also not easy - the treatment methods currently applied to Acid Mine Drainage are also likely to It is very difficult to avoid the contamination of water through create a considerable amount of waste, which will need to Acid Mine Drainage during the mining process.186 AMD is be minimised and managed.199 produced when sulphide bearing rocks are exposed to

Water hungry coal: Burning South Africa’s water to produce electricity 15 At risk: The Olifants River Liability

The Olifants River supplies both Eskom and the Kruger Acid Mine Drainage is a long-term problem - the National Park with water.200 However, the catchment contaminated water may well seep into this country’s water area has experienced more than 100 years of coal table for centuries.208 The issue of who is to blame for this mining, and is now an area that is seriously degraded, crisis, and also of who will bear the costs of fixing the with polluted, low quality water.201 202 Despite this, the problem is a contested one. In the end, whatever solution is water supply is seen to be essential for the continued sought for AMD, it is likely to cost South African taxpayers operation of many coal-fired power stations and their billions of Rand - particularly given the high number of satellite collieries. This river system is showing signs abandoned mines, which now fall under the State’s duty of of serious water pollution, soil erosion and reduced care. This means that despite the existence of laws placing agricultural production, and similar symptoms are the responsibility for mining impacts on mine owners starting to appear in the Vaal River Catchment.203 themselves,209 the mining companies that created this Indeed, the ever-growing contaminant-loading of the problem may not in fact be held liable. Vaal River system has now reached the point where urgent steps must be taken to limit and remove the Although the National Water Act (Act no. 36 of 1998) sources of contamination.204 The extensive pollution supports the ‘polluter pays’ principle, which means that of surface and groundwater also leads to escalating mines creating, permitting or causing pollution should be competition between key sectors for this scarce held liable for the cost of cleaning up pollution (including resource.205 Acid Mine Drainage), in reality enforcement of this principle remains problematic.210 In addition, although a pre-feasibility Ironically, in the Olifants catchment, coal mining has study on dealing with AMD is under way, the apportionment polluted streams and rivers so significantly that it of liabilities is confidential, and may never be released into cannot be used in Eskom’s coal-fired power stations. the public domain.211 This means that Eskom’s water must either be treated, which costs more money and uses more energy, or the water must be supplied from a different river system that has not been contaminated by mining.206 The issue of water supply is complicated even further by the very real possibility that global climate change is likely to have an adverse effect on water availability throughout Southern Africa, in addition to the water quality concerns from pollution.207 © Greenpeace / Oswald Chikosi 2011.

16 Water hungry coal: Burning South Africa’s water to produce electricity Water SouthAfrica’s hungrycoal:Burning watertoproduce electricity 17

© Greenpeace / Graeme Williams 2008. 3. Eskom’s “efficiency” efforts

Dan Marokane, Eskom’s chief commercial officer, has been used to burn coal to create electricity are simply not good quoted as stating that water is just as important to the enough, and are certainly not an attempt to save every drop economy as coal. According to him: “Every drop of water of water possible. In reality, Eskom has failed to recognise that we can save counts and water is one area that is that the way it currently generates, transmits and distributes receiving high priority”.212 electricity is flawed and unsustainable, with substantial, unavoidable and long-lasting impacts. As a state-owned company, Eskom’s performance is also measured by the overall value that it adds to the lives of 3.1. Eskom’s thirst for water: incremental the people of South Africa. According to Eskom, the utility efficiency and pollution reduction takes environmental sustainability ‘very seriously’ and claims to be working to diversify its energy mix, reduce its measures environmental footprint and lower carbon emissions.213 This is an interesting interpretation of the utility’s core business, Eskom’s power stations are dependent on a steady, which accounts for more than 60% of South Africa’s adequate supply of high-quality water,222 and the utility emissions,214 and has prioritised coal to the exclusion of all claims to recognise that competing resource needs, other options, creating huge water costs that the people of drought, pollution and poor water supply infrastructure this country have to bear. all have the potential to hamper its access to affordable water.223 However, despite these limitations, the utility Despite their seemingly convincing public statements, to shows no signs of shifting away from water-intensive coal- date Eskom’s response to concerns about its water use fired electricity generation. has been limited to highlighting efficiency gains by the newest coal-fired power stations (both Medupi and Kusile There are a number of issues that contribute to higher will be supercritical stations and they will use dry-cooling than necessary water usage at Eskom’s coal-fired power technology), and depending on inter-basin water transfer stations: the age and thermal efficiency levels of existing schemes for the water supply of these stations.215 The two stations - which means that the older and less thermally coal-fired power stations will be two of the largest coal- efficient current stations are, the higher the water demands fired power stations in the world.216 Yet Eskom argues that will be; declining coal quality - which means that more coal although Kusile and Medupi will increase the utility’s total must be burnt to produce the same amount of electricity; carbon footprint, the technology and design of the power and declining raw water quality supplied to stations - which stations is more efficient compared to existing coal-fired means that more clean water is needed for dilution.224 225 226 power stations, resulting “in a reduction in water usage and carbon dioxide emitted per unit of electricity generated”.217 Burning coal to produce electricity is one of the most While the design of the new coal-fired power stations destructive practices on the planet, and both Medupi and will be more efficient (reducing water usage and carbon Kusile will produce significant pollutants and greenhouse dioxide emitted per unit of electricity produced),218 in reality gas emissions. Kusile will increase South Africa’s these power stations will substantially increase the utility’s contribution to climate change by nearly 10%,227 but it is total carbon footprint. And it is estimated that Kusile will also likely to have significant health impacts. Coal-fired consume a massive 26.15 million m3 of water per year that power stations are a significant contributor to atmospheric it operates.219 pollution levels in South Africa228 because even when using pollution-reduction technologies, burning coal to generate The utility has clearly stated that it is working to minimise electricity produces substantial pollution by-products.ix 229 its water use, through using dry cooling technology in These pollutants have been linked to bronchitis, lung cancer, new coal-fired power stations, and reusing water in older asthma, leukaemia and pulmonary disease,230 which means plants.220 But there are severe limitations to efficiency gains, that coal-fired electricity and coal expansion has significant and reductions in emissions and water use per unit of impacts on people’s health - both for the people who work electricity are essentially meaningless when by the utility’s in coal mines/coal-fired power stations, but also for the

own admission, its absolute CO2 footprint will continue to surrounding communities. As a result, Eskom is required to grow.221 In addition, Eskom’s water-use for its coal-fired power stations will push this country closer to a water crisis. ix These include carbon dioxide, methane, carbon monoxide, In light of global water scarcity and catastrophic climate oxides of nitrogen, sulphur dioxide, mercury, total mass of change, incremental improvements in the technology suspended particulate matter, and a range of carcinogenic radionuclides and heavy metals (Riekert, J. 2011).

18 Water hungry coal: Burning South Africa’s water to produce electricity make an effort to reduce the atmospheric emissions from But the use of CCS also has massive implications for South new coal-fired power stations by using the latest technology Africa’s water resources. It is estimated that coal-fired to reduce emissions at both Medupi and Kusile. However, power stations using CCS technology will need a staggering in an ironic twist of fate, in order to reduce atmospheric 90% more water than those without, as many of the capture emissions from burning coal, Eskom will require more water. processes need wet cooling. This is likely to worsen water This is true for Flue Gas Desulphurisation (FGD), and also shortages, already exacerbated by climate change.239 In for Carbon Capture and Storage (CCS). addition, as long as CO2 is stored underground, there is a

risk of leakage, which means that any CO2 release could Carbon Capture and Storage (CCS) impact on the surrounding groundwater, air or soil, with catastrophic implications. It is entirely possible that brine

CCS aims to reduce the impact of burning fossil fuels by contaminated by the CO2 could leak into the aquifers that 240 capturing carbon dioxide (CO2) and storing it underground. supply drinking and irrigation water. Both Medupi and Kusile will be ‘carbon capture ready,’x which means that they will be able to install carbon Concerns about the costs, feasibility, safety, liability, capture equipment should the technology ever be ready or inefficiencies and water implications of CCS make ita affordable in the future. Its future development has been dangerous gamble, which South Africans simply cannot widely promoted by the coal industry as a justification for afford.241 the construction of new coal-fired power stations, arguing that it will magically remove the constraints around coal.231 Flue Gas Desulphurisation (FGD) However, there are serious limitations to CCS:

The significant amount of sulphur dioxide (SO2) produced by • CCS technology is still under development and there is the combustion of coal can be partially scrubbed out of the substantial doubt that CCS will ever be able to deliver.232 exhaust flue gases by various Flue Gas Desulphurisation technologies.242 243 Eskom’s existing coal-fired power • If the technology ever works, it would not deliver in time stations do not yet use advanced technology to reduce to avert catastrophic climate change. It is estimated that emissions.244 the earliest possibility for deployment of CCS at utility scale would not be before 2030, which means that even However, Kusile will have a Flue Gas Desulphurisation if CCS were to work, it would deliver far too late to avoid plant (only once it is fully operational), and Eskom plans dangerous climate change.233 to retrofit Medupi with this technology.245 A number of FGD technologies exist, all of which are associated with • CCS is unaffordable in South Africa, and could lead to a substantial capital and operating costs. The most common doubling of plant costs and cause electricity price technology for reducing sulphur dioxide emissions is by increases of between 21% and 91%.234 scrubbing the exhaust flue gas with water containing an alkaline substance such as limestone.246 • Storing carbon underground is risky. The safe and 235 permanent storage of CO2 cannot be guaranteed. Eskom estimates that FGD will remove an estimated 90% of sulphur emissions.247 However, Flue Gas Desulphurisation • CCS wastes energy. Ironically, in the unlikely event requires water, irrespective of the technology type that is that CCS technology were to work, it would mean major chosen, to the extent that the water requirements of a wet reductions in plant efficiency, and could use a massive FGD system would significantly increase the water use of 10% to 40% of the energy produced by a power station, dry cooled power stations such as Medupi and Kusile.248 effectively reducing electricity output from coal-fired power stations such as Kusile by more than a third.236 In addition, the use of FGD will generate substantial volumes of effluent from the dewatering and gypsum washing • CCS carries significant liability risks if something were to process. This wastewater will have a high nitrate, heavy go wrong.237 It poses a threat to health, ecosystems and metal and chloride content and will need to be disposed the climate. In fact, the industry itself does not completely of.249 trust the technology either, given its unwillingness “to fully invest in CCS without a framework that protects it from long-term liability”.238

x The International Energy Agency (IEA) defines a ‘capture- ready plant’ as one “which can be retrofitted with CO2 capture when the necessary regulatory or economic drivers are in place” (International Energy Agency (IEA) Greenhouse Gas R&D

Programme. 2007. CO2 capture ready plants).

Water hungry coal: Burning South Africa’s water to produce electricity 19 4. Who really controls the water?

The overall impacts of water use during electricity production not operate with statistics that feature the full cycle of water are currently underestimated, and nearly 2% of South needed for the production of coal-fired electricity raises Africa’s water is allocated to a single entity: Eskom.250 These serious concerns. And if the country has already allocated two issues raise major concerns around transparency and water resources to the maximum, and is facing a potential accountability in terms of water allocation and management deficit in the near future, this legitimately raises the question: in South Africa. how are Eskom’s increased water needs for Kusile and Medupi being factored into water resource allocations? And if the Department of Water Affairs truly believes that water 4.1. Water and the electricity sector “demand must be managed and water used as efficiently as possible,”258 why is Eskom not being pushed to invest in Eskom itself admits that in the process of generating much more water efficient renewable energy technologies electricity, the utility is a significant user of the country’s instead of coal? fresh water,251 using a staggering 10 000 litres of water per second.252 The electricity sector, dominated by Eskom, 4.2. Transparency and water licences: the is frequently said to consume ‘only’ 2% of South Africa’s litmus test for democracy? water,’253 which translates to 1.76% of national water supply going to coal-fired electricity generation,254 compared to the 3% that goes to the industrial sector.255 While it is The water problems associated with coal do not end at the worrying that almost 2% of South Africa’s water is going to water required to operate Eskom’s coal-fired power stations, a single entity, this statistic is also misleading, because it or the additional technology required to reduce emissions, clearly does not take into account the water used during or even the water depletion and pollution from coal mining. coal extraction, processing, pollution reduction processes, and the disposal of contaminated by-products. Wassung256 Of the 22 mines that supply Eskom with coal, half were therefore estimates that the full coal power generation operating without a valid water licence in 2010.xi 259 In an process actually requires approximately 4.84% of national example of severe contravention of existing legislation, the water supply - more than double the original statistic. Arnot colliery in Mpumalanga had not even attempted to apply for a licence in 2010, yet it was allowed to continue Whatever the percentage of South Africa’s water that the operations.260 The current state of valid licences remains utility uses, the requirements of coal-fired power stations can be substantial in relation to the local water resources

and catchments, because the majority of South Africa’s xi The licences were either still being processed by the coal and coal-fired power stations occur in the drier parts Department of Water Affairs, outstanding information had to be 257 submitted or there simply had been no application for a water of the country. The fact that national water planning does licence at all. © Greenpeace / Tony Marriner 1989. Tony © Greenpeace /

20 Water hungry coal: Burning South Africa’s water to produce electricity unclear due to issues around transparency and the kind of substantial number of users seem to operate without valid information that is allowed into the public domain. Eskom water licences, and that the full amount of water needed claims to be working closely with the Department to address during electricity generation is not completely factored the backlog of water-use licence applications for its power in. Eskom’s lack of transparency and accountability in its stations and coal suppliers.261 But in essence, the utility has water use is potentially accelerating an impending water failed to ensure that all of the mines that supply it with coal crisis, leaving ordinary South Africans to pay the price. This have valid water licences. also raises the question as to whether South Africa’s water resources have not only been allocated to the maximum, Clearly, the lack of valid water licences and effective water but may have already exceeded the maximum. management and licensing processes create severe limitations to the accountability of users, and threatens Despite water being classified as a common good by the the protection of South Africa’s scarce water resources.262 National Water Act (Act no. 36 of 1998),264 a great deal of There is a serious lack of transparency regarding water information related to water use and allocation is classified management plans and water licences in South Africa, as confidential, which makes it impossible to assess with most of this information remaining confidential, with whether water resources may already have been over- access restricted. How disclosure of this information could allocated. The question remains: who actually controls the result in negative consequences for mining companies use and allocation of water in South Africa? Water insecurity or Eskom, and the reasons for this lack of transparency is already a present reality and not a fiction of the future. around water use and water-related practices remain unclear. Instead, greater transparency supported by the 4.3. Extreme water supply options: water enforcement of appropriate legislation by key government transfer schemes and desalination departments such as the Department of Water Affairs would encourage more effective and efficient water use, while also reducing operating costs. Confidentiality in the water sector Water transfer schemes disempowers the public, effectively removing our ability to hold industry accountable for its water use, particularly Neither Medupi nor Kusile will obtain the water that they given that no part of South Africa’s water resources are need to operate from local sources, because the rivers regarded as ‘private property’.263 are either too polluted from mining, or do not have enough capacity. Instead, expensive inter-basin water transfer Furthermore, it seems impossible for transparent and schemes will be needed to supply the mega coal-fired effective planning and allocation of water resources to take power stations with the water that they need to operate.265 place if water use is not fully accounted for, given that a © Greenpeace / Jennifer Bruce 2012.

Water hungry coal: Burning South Africa’s water to produce electricity 21 Water for Kusile will not be sourced from within the Olifants be able to cope with additional pressure in the future? And if River catchment, but will be supplied from the Vaal River not, will Kusile obtain water at the expense of the people in system instead, through the Vaal River Eastern Sub-system Gauteng, as well as the farmers and local communities who Augmentation Project (VRESAP).266 The Vaal River system depend on the river for their livelihoods - sparking possible supplies water to approximately 60% of South Africa’s water conflicts? economy and an estimated 45% of the country’s population267 (approximately 20 million people).268 The VRESAP project is Desalination initiated by the Department of Water Affairs and is aimed at transferring approximately 160 million m3 of water from the Desalination refers to the treatment of saltwater or brackish Vaal River Dam to meet the growing water requirements of groundwater to recover useable water (mainly for the Eskom and Sasol.269 agricultural and industrial sectors, although for use as drinking water has also been considered).273 Desalination is The Department of Water Affairs has given its assurance often perceived to be a future source of fresh water, and the that VRESAP would be able to supply all of Kusile’s water Department of Water Affairs believes that desalination will requirements, despite the fact that the Vaal River is already play an important role in the country’s future water security.274 showing signs of pollution.270 Worryingly, this means that However, there are serious limitations to desalination as the the impacts of VRESAP were not actually considered in technology remains relatively expensive.275 the Kusile Environmental Impact Assessment (EIA) report, since the impacts associated with abstraction from the Vaal There are various desalination techniques (including reverse River system were considered as part of the VRESAP EIA.271 osmosis, vapour compression and electrodialysis), but all This means that the EIAs for both Medupi and Kusile made of these techniques are highly energy-intensive.276 And assumptions that because Eskom is of strategic importance although desalination plants do exist, they have significantly the water needed for the coal-fired power stations to operate higher costs than even effluent re-use does. According to would somehow be made available. However, this raises the 2009 Water for Growth and Development Framework, significant questions about whether the overall impacts of the only intervention that would be more expensive than Kusile’s water use are fully reflected in Kusile’s EIA, or were desalination is inter-basin transfers.277 fully considered before the coal-fired power station was given the go-ahead. Desalinated seawater may be a possible future solution for coastal cities if the technology becomes more cost- In reality, despite the fact that the Department claims that competitive, but it will not work for inland areas due to the VRESAP would be able to supply all of Kusile’s water prohibitive costs of transporting the desalinated water over requirements, Eskom claims that at their request “the long distances.278 This means that desalination may alleviate Department of Water Affairs is investigating potential some of the future strain on South Africa’s water resources infrastructure bottlenecks in the Vaal River water supply (for a price), but it is not a future solution to supplying new system,”272 indicating that Kusile’s water supply is far from coal-fired power stations with water, as the country’s coal secured. The Vaal River also supplies Gauteng with its resources occur inland. water, and this begs the question: will the Vaal River system © Greenpeace / Graeme Williams 2008.

22 Water hungry coal: Burning South Africa’s water to produce electricity Water SouthAfrica’s hungrycoal:Burning watertoproduce electricity 23

© Greenpeace / Oswald Chikosi 2011. 5. Greenwashing: Eskom’s renewable energy efforts

Eskom states that it takes environmental sustainability, compulsory components of the utility’s controversial World water use and climate change seriously and has a number Bank loan for Medupi.283 This begs the question: is Eskom of strategies and plans to back up this claim.279 However, interested in investing in renewable energy at all, or has the whether these strategies are a) accessible to the public, utility been pushed to invest in this minimal amount, which and b) able to significantly reduce Eskom’s carbon/water is a useful token decoration for its polluting coal-fired power footprint is another matter. Per unit of electricity produced, stations? Kusile would use a massive 173 times more water than wind power would use, given that wind power uses virtually Clearly, if we are to take Eskom’s stated positions on no water.280 The utility continues to invest in incremental environmental sustainability, water and climate change efficiency changes for its coal-fired power stations, instead seriously, then the utility would be investing substantially in of implementing a complete paradigm shift in electricity renewable energy systems instead of investing in slightly generation. Investing in renewable energy would more efficient coal-fired power stations, and renewable significantly reduce emissions and water use and pollution energy additions to existing coal-fired power stations.284 - but Eskom shows no intention of shifting away from coal 285 Anything less than a complete electricity generation and towards renewable energy. paradigm shift away from coal and towards renewable energy technologies is simply Business As Usual, hidden Eskom has installed solar panels at its Megawatt Park behind empty rhetoric. headquarters and also at the Kendal and Lethabo coal- fired power stations to supplement auxiliary power. This The ‘solutions’ Eskom proposes are not the answer at all. programme will likewise be rolled out across Eskom’s fleet In effect, they amount to inadequate efficiency measures, of coal-fired power stations.281 Sadly, this appears to amount augmenting water supply through inter-basin water to little more than greenwashing, given that the utility is transfers, and short-sighted technology adjustments. currently building Kusile and Medupi, which will result in These are all expensive technology-fixes that are unable nearly 10 000MW of new coal-fired electricity, compared to fundamentally tackle the causes of climate change with its minimal renewable energy plans - amounting to and water scarcity. Technological changes can be part of 100MW of wind, and 100MW of solar. The utility expects the the solution, if changes are made to the way electricity construction of the 100MW Sere wind project in the Western is currently produced. However, superficial upgrades Cape to begin during 2012,282 but has no clear timelines or of outdated energy generation models and efficiency implementation plans for the 100MW solar plant. The 100MW measures will not be enough. Clearly, more fundamental of wind and 100MW of solar were actually incorporated as shifts are required. © Greenpeace / Shayne Robinson 2011.

24 Water hungry coal: Burning South Africa’s water to produce electricity 6. The solution to South Africa’s water and electricity crisis: An Energy [R]evolution

Renewable energy is not a future technology. It is mature R42 billion per year that Kusile will operate - and this is only and can be deployed through both large-scale and taking into account the water use of the power station.290 decentralised projects. Eskom appears to be in denial. At the high end, the estimated total social damage cost (or What would be a game-changer and radically reduce externality cost) of Kusile is economically very significant, Eskom’s demand for water, together with avoiding an and could amount to R60.6 billion a year that it operates.291 electricity crisis, would be to substantially diversify the energy mix away from coal and towards renewable The real solution to South Africa’s water and electricity energy.286 Indeed, solar PV and wind-power use virtually no crisis is not incremental improvements in coal technology, water during operation.287 Coal-fired power stations (even it is in fact an Energy [R]evolution: a shift away from coal those using the most up-to-date technology) use significantly and nuclear energy, and towards renewable energy and more water compared to the water needed for most comprehensive energy efficiency measures. In this scenario, renewable energy technologies.288 Table 1 clearly shows the neither Kusile, nor the six new nuclear reactors proposed significant water savings of investing in renewable by the government need to be built to meet the growing technologies instead of even the most efficient, demand for electricity. The Advanced Energy [R]evolution technologically advanced coal-fired power station (Kusile). scenario demonstrates that transforming how we use energy is achievable, and provides a wealth of opportunities Table 1: Comparison of water use of different technology to stimulate economic growth, ensure affordable access types289 to electricity for all, and create green, sustainable jobs. If this scenario were implemented with enough urgency and Technology type Water use ambition, nearly 50% of South Africa’s electricity could be

3 supplied by renewable energy by 2050, and as renewable Dry-cooling coal-fired power station 0.66 m /MWh 292 energy is scaled up, we can start phasing out coal. (Kusile)

Concentrated solar power with 0.296 m3/MWh Rather than simply comparing the water footprint of renewable energy technologies to that of coal, Greenpeace parabolic trough (dry cooling) has mapped the impacts of two different pathways, to Wind 0.0038 m3/MWh assess which would be the better choice for the country, in the specific context of water use. The graph below compares The vast majority of renewable forms of electricity water usage for two scenarios in 2030 (compared to a generation use substantially lower amounts of water, and 2007 baseline): The Reference Scenario (modelled on the not considering these alternatives results in high opportunity IRP2010 scenario) and Greenpeace’s Advanced Energy costs. In fact, investing in another new coal-fired power [R]evolution scenario.293 station (Kusile) equates to a hidden cost of an estimated

Graph 1: Water use for energy in South Africai

i The water footprint of thermal power generation and fuel production is estimated by taking the production levels in each scenario and multiplying by technology-specific water consumption factors.

Water hungry coal: Burning South Africa’s water to produce electricity 25 The graph clearly shows that Greenpeace’s Energy decrease the amount of water required for electricity [R]evolution scenario maps a pathway to a low-carbon, production in the country: to half of what would be low-risk energy system with minimal disturbance to water required for coal mining and coal power combined, and supplies. This scenario is able to minimise both the direct to a level even lower than the 2007 baseline. impacts of energy systems on water and the risk of catastrophic impacts on water supplies through climate A complete transition to renewable energy and energy change. Substantial amounts of water are required for both efficiency is technically possible, and would help solve both coal mining and coal power in the Reference scenario, the electricity and water crises facing South Africa;294 all that pushing water use for energy production up to nearly is missing is the political will to make this shift happen. By three billion m3/year by 2030. On the other hand, electricity shifting away from coal and nuclear energy and towards technologies with low to no water requirements (energy renewable energy systems, substantial amounts of scarce efficiency, wind and solar PV) are substituted for coal water could be saved and diverted to other sectors where it power generation with high water impacts in the Energy is urgently needed, avoiding water insecurity and potential [R]evolution scenario. The graph illustrates that conflict,295 while also creating green jobs and a sustainable, implementing an Energy [R]evolution would not only clean future. stimulate the country’s economy, but would drastically © Greenpeace / Shayne Robinson 2011.

26 Water hungry coal: Burning South Africa’s water to produce electricity 7. Conclusion

South Africa has limited coal and water resources, and the that building more coal-fired power stations and increasing country is reaching a point of no return. We are nearly at the coal mining to supply them will actually send South Africa limits of our water resources, and are likely to face an even into a water deficit, given that all of the water available in more significant water crisis by as early as 2025.296 The this country has essentially already been allocated.301 302 energy decisions that are made today will influence the structure and stability of South Africa’s economy for decades South Africa is therefore facing huge political decisions to come. The choice to continue investing in coal-fired related to where the country’s water should be allocated in electricity means that Eskom is a substantial water user, the future. It is also a country that faces potential conflicts effectively putting South Africa’s water resources at risk. over access to water and water rights due to increasing water scarcity. It is clear that water scarcity and the energy crisis are inextricably linked, and that the allocation of water must Increasing the number of coal-fired power stations in the take the principles of equity, efficiency (or beneficial use) country will unfortunately solve nothing. There are clear and and sustainability, as prescribed by the National Water Act very real benefits to shifting away from coal and towards (Act no. 36 of 1998),297 into account. It is still possible to pull renewable energy, which would create jobs, stimulate the back from the brink of a water crisis that could potentially economy, reduce the country’s contribution to catastrophic throw South Africa into chaos, but only if water demand is climate change, and would be the best socioeconomic use significantly reduced, and the resource is managed and of the country’s dwindling water resources. However, this allocated effectively and transparently.298 shift must be made urgently, and ambitiously.

According to the National Water Act (Act no. 36 of 1998),299 Unfortunately, we are already suffering from the unintended the government has the responsibility to allocate water consequences of past choices, as the problems we face equitably and in the public interest. The first steps towards have become more complex over time.303 A water crisis is efficient and effective water use are transparency and looming in South Africa,304 and investing in new coal-fired accountability, which would then lead to the sustainable power stations instead of renewable energy and energy allocation of resources.300 Clearly, the current allocation of efficiency puts all South Africans at risk. water to the coal mining industry and to Eskom for coal-fired electricity is not a transparent, accountable or sustainable Fortunately, we are still in a position where we are able decision. Neither is it in the public interest, given that to make choices, but they need to be the right ones, and there are very effective substitutes for coal, but there they need to be made now. It is time to end the era of are no alternatives to water. Both in the short term and the coal in South Africa through a just transition away from long term, these industries contribute to water scarcity, and coal towards renewable energy. Our ability to deal with a substantial environmental and health impacts. It is very likely changing climate and future water insecurity depends on it. © Greenpeace / Benedicte Kurzen 2011.

Water hungry coal: Burning South Africa’s water to produce electricity 27 8. Greenpeace recommendations

Water is a critical resource, which is under threat. Therefore, publicly available by the Department of Water Affairs and South Africa’s exceptionally high levels of water insecurity the Department of Mineral Resources. combined with further coal expansion could push this country closer to the brink of a series of water crises and water conflicts: The Department of Water Affairs should ensure that activities at coal mines operating without valid water use • The South African government should immediately licences are suspended with immediate effect until valid prioritise renewable energy over water intensive coal- licences are in place. fired electricity. The enforcement of appropriate legislation by the • As part of a just transition away from coal, Kusile Department of Water Affairs and the Department of should be cancelled, there should be no further Mineral Resources is critical to ensure more effective and investments in coal-fired power stations and Eskom efficient water use, while also reducing operating costs. should shift these investments towards renewable energy instead. Thus far, the government has not been able to produce overarching documentation that proves that South Africa’s Government Departments water resources have not in fact already been over- allocated. In the light of the fact that water is a common South Africans have a right to know how scarce water good, which the government has the responsibility to resources are being allocated, managed and polluted. distribute equitably, the Department of Water Affairs must Confidentiality in the water sector disempowers the public, produce proof that South Africa is not already at the limits of effectively removing our ability to hold industry accountable the water that can be allocated. for its water use, particularly given that no part of South Africa’s water resources are regarded as ‘private property’.305 Adequate measures must be taken by the Department of In the interests of transparency and accountability, the Water Affairs and the Department of Mineral Resources Department of Water Affairs should ensure that all of the to urgently deal with Acid Mine Drainage, which holds information around water management plans, reconciliation the mining companies liable, rather than South African studies, the prioritisation of water supply to strategic users taxpayers. and water use licences are publicly accessible. Eskom The Department of Water Affairs should conduct a strict and robust water demand assessment for Kusile coal-fired Eskom should produce and implement a 20-year renewable power station, and any other kind of coal expansion in energy roadmap, outlining its commitment to begin investing South Africa. These assessments would need to take into in significant amounts of renewable energy. account the costs of inter-basin transfer schemes and the implications of climate change for future water availability, Eskom is responsible for its supply chain. As a result, the and must be made public. utility must be accountable and held liable for ensuring that the coal mines that supply the utility do actually operate with Given that the Department of Water Affairs clearly states valid water licences. that water demand must be managed, and water used as efficiently as possible,306 the most effective way to manage Eskom should explicitly quantify, and incorporate the the water demand for the electricity sector is for Eskom negative externalities of coal-fired electricity generation into to shift towards relatively ‘water-free’ renewable energy the costs of new coal-fired power stations. This information technologies. Accordingly, government departments must be in the public domain. (including the Department of Water Affairs and the Department of Energy) should ensure that Eskom Eskom should immediately begin a shift away from coal- immediately begins to shift significant investments towards fired electricity generation to relatively ‘water-free’ renewable renewable energy as an alternative to coal. energy electricity generation. Implementing an Energy [R]evolution would not only deliver sustainable electricity The impacts of choosing to invest in coal-fired electricity for all South Africans, but would drastically decrease the instead of renewable technologies have not been amount of water required for electricity production in the transparently assessed. Therefore, a thorough public country. This would mean that nearly 50% of South Africa’s investigation of the full water use of the electricity and electricity could be supplied by renewable energy by 2030. coal mining sector should be initiated by the Department of Water Affairs in collaboration with the Department of The health, water and other social impacts of coal use and Mineral Resources and the Department of Energy. coal mining should be recognised, quantified and mitigated by the State and by polluters, including Eskom. This Detailed information about the decisions made around water information must be in the public domain. use licences and coal mining should immediately be made

28 Water hungry coal: Burning South Africa’s water to produce electricity Water SouthAfrica’s hungrycoal:Burning watertoproduce electricity 29

© Greenpeace / Jennifer Bruce 2012. 9.References

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Water hungry coal: Burning South Africa’s water to produce electricity 33 1 Inglesi-Lotz, R. and Blignaut, J. 2011. Estimating the opportunity cost of water for the Kusile and Medupi coal-fired electricity power plants in South Africa, p.88 in Blignaut, J. et al. 2011. The external cost of coal-fired power generation: The case of Kusile. Unpublished research paper.

2 Turton, A. 2008. CSIR Keynote address: Three Strategic Water Quality Challenges that Decision-Makers Need to Know About and How the CSIR Should Respond. CSIR Report No. CSIR/NRE/WR/ EXP/2008/0160/A. Available online: http://www.environment.co.za/documents/water/KeynoteAddressCSIR2008.pdf.

3 Department of Water Affairs and Forestry. 2009. Water for Growth and Development Framework: Version 7. Available online: http://www.dwaf.gov.za/WFGD/documents/WFGD_Frameworkv7.pdf.

4 Wassung, N. 2010. Water Scarcity and Electricity Generation in South Africa. Thesis, MPhil degree in Sustainable Development, University of Stellenbosch, School of Public Management and Planning, Stellenbosch, South Africa. Available online: http://www.sustainabilityinstitute.net/newsdocs/document-downloads/doc_download/558-natalie-wassung-water-scarcity-and-electricity-generation-in-south-africa.

5 Eberhard, A. 2011. The Future of South African Coal: Market, Investment, and Policy Challenges. Stanford Progam on Energy and Sustainable Development: Freeman Spogli Institute for International Studies. Available online: http://iis-db.stanford.edu/pubs/23082/WP_100_Eberhard_Future_of_South_African_Coal.pdf.

6 African National Congress (ANC). 2012. Maximising the Developmental Impact of the People’s Mineral Assets: State Intervention in the Minerals Sector (SIMS). Policy Discussion Document, March 2012.

7 Wassung, N. 2010. op. cit.

8 Turton, A. 2008. op.cit.

9 Eskom Holdings Limited. 2011a. The Eskom Factor: p.44. Available online: http://www.eskom.co.za/content/EskomFactor.pdf.

10 Eskom Holdings Limited. 2011b. Eskom Integrated Report 2011. p. 14. Available online: http://financialresults.co.za/2011/eskom_ar2011/index.php.

11 International Energy Agency (IEA). 2011. Key World Energy Statistics. Available online: http://www.iea.org/publications/freepublications/publication/name,26707,en.html.

12 Wassung, N. 2010. op. cit.

13 Inglesi-Lotz, R. and Blignaut, J. 2011. op.cit. p.88.

14 Wassung, N. 2010. op. cit.

15 Eskom Holdings Limited. 2011a. op. cit. p.4.

16 Molewa, E. 2012a. Speech by the Honourable Edna Molewa, Minister of Water and Environmental Affairs on the occasion of the Budget Vote for Water Affairs, Parliament: “Water is life – Respect it, Conserve it, Enjoy it’. Available online: http://www.info.gov.za/speech/DynamicAction?pageid=461&sid=27434&tid=68254.

17 Department of Water Affairs and Forestry. 2009. op. cit.

18 Republic of South Africa. 1998. National Water Act. Government Gazette, 26th August: 398: 19182. Available online: http://www.info.gov.za/view/DownloadFileAction?id=70693.

19 Wassung, N. 2010. op. cit.

20 Ibid.

21 Questions posed to the Department of Water Affairs. Information held by Greenpeace Africa. September 2012.

22 Wassung, N. 2010. op. cit.

23 Republic of South Africa. 1998. op. cit. p.2.

24 Inglesi-Lotz, R. and Blignaut, J. 2011. op. cit. p.88.

25 Wassung, N. 2010. op. cit.

26 Von Uexkull, O. 2004. Energy and Water: The ignored link. Refocus. March/April 2004: p. 40-44. Available online: http://www.oilcrisis.com/waterways/EnergyAndWater_Uexkull.pdf.

27 Inglesi-Lotz, R. and Blignaut, J. 2011. op. cit. p.88.

28 Blignaut, J., Koch, S., Riekert, J., Inglesi-Lotz, R. and Nkambule, N. 2011. The external cost of coal-fired power generation: the case of Kusile. p.18 in Blignaut, J. et al. 2011. Business Enterprises: University of Pretoria: unpublished research paper.

29 Wassung, N. 2010. op. cit.

30 Department of Water Affairs and Forestry. 2004. National Water Resource Strategy: Our blueprint for survival. First Edition. ch.2, p.52. Available online: www.dwaf.gov.za/Documents/Policies/NWRS/ Default.htm.

31 Eskom Holdings Limited. 2012. Integrated Report for year ended 31 March 2012. Fact sheets: 4. Supply of water and coal. Available online: http://financialresults.co.za/2012/eskom_ar2012/fact- sheets/004.php.

32 Greenpeace and the European Renewable Energy Council. 2011. the advanced energy [r]evolution: a sustainable energy outlook for South Africa. 2nd edition South Africa energy scenario. Available online: http://www.energyblueprint.info/fileadmin/media/documents/national/2011/E_R__South_Africa_May_2011-LR.pdf.

33 Eberhard, A. 2011. op. cit.

34 Constitution of the Republic of South Africa. 1996. Chapter 2 - Bill of Rights. Available online: http://www.info.gov.za/documents/constitution/1996/96cons2.htm.

35 Constitution of the Republic of South Africa. 1996. op. cit.

36 Turton, A. 2008. op.cit.

37 Von Uexkull, O. 2004. op. cit.

38 Department of Water Affairs and Forestry. 2009. op. cit.

39 Wilson, W., Leipzig, T. and Griffiths-Sattenspiel. 2012. Burning Our Rivers: The Water Footprint of Electricity. The River Network. Available online: http://climateandcapitalism.com/files/2012/06/Burning- Our-Water.pdf.

40 Potgieter, P. H. 2010. Water and energy in South Africa – managing scarcity. Munich Personal RePEc Archive: University of South Africa. Available online: http://mpra.ub.uni-muenchen.de/23360/1/ MPRA_paper_23360.pdf.

41 Wassung, N. 2010. op. cit.

42 Lester, A., Nel. E. and Binns, T. 2000. South Africa Past, Present and Future: Gold at the end of the rainbow? Longman: Harlow.

43 Republic of South Africa. 1998. op. cit. p.2.

44 Binns, J.A., Illgner, P.M. and Nel, E.L. 2001. Water shortage, deforestation and development: South Africa’s Working for Water programme. Land Degradation and Development, 12: 341-355. Available online: Available online: http://planet.uwc.ac.za/nisl/invasives/Assignment1/Binns.pdf.

45 Eskom Holdings Limited. 2009. Eskom Annual Report 2009. p.23. Available online: http://www.financialresults.co.za/eskom_ar2009/.

46 Wassung, N. 2010. op. cit.

47 Turton, A. 2008. op.cit.

48 Ibid.

49 Turton, A. 2008. op.cit. p.2.

50 Ibid.

51 Republic of South Africa. 1998. op. cit. p.2.

52 Potgieter, P. H. 2010. op. cit.

53 Ibid.

54 The Water Wheel. 2009. The State of Water in South Africa – Are we Heading for a Crisis? South African Water Research Commission. September/October 2009, p. 31-33. Available online: http://www. wrc.org.za/Knowledge%20Hub%20Documents/Water%20Wheel/Articles/2009/05/WW_09_Sep-Oct_water%20crisis.pdf.

55 Department of Water Affairs and Forestry. 2009. op. cit.

56 Constitution of the Republic of South Africa. 1996. op. cit.

57 Molewa, E. 2012a. op. cit.

58 Coovadia, H., Jewkes, R., Barron, P., Sanders, D. and McIntyre, D. 2009. The health system of South Africa: historical roots of current public health challenges. The Lancet 374(9692): 817-834.

59 Department of Water Affairs and Forestry. 2009. op. cit.

34 Water hungry coal: Burning South Africa’s water to produce electricity 60 Republic of South Africa. 1997. Water Services Act. Government Gazette, 19th December: 390:18522. p.10. Available online: http://www.dwaf.gov.za/Documents/Legislature/a108-97.pdf.

61 Department of Water Affairs and Forestry. 2002. Free Basic Water: Questions and Answers. Available online: http://www.dwaf.gov.za/documents/fbw/qabrochureaug2002.pdf.

62 Potgieter, P. H. 2010. op. cit.

63 Department of Water Affairs. 2010. Strategic Overview of the Water Sector in South Africa 2010. DWA Directorate: Water Services Planning and Information Version 0.9 – Printed 24 August 2010. Available online: http://www.dwaf.gov.za/dir_ws/wsnis/relatedInfo/A6_Strat_Overview_2010_08_ver_02M_email.pdf.

64 Binns, J.A., Illgner, P.M. and Nel, E.L. 2001. op. cit.

65 Department of Water Affairs. 2009. op. cit.

66 Department of Water Affairs. 2012a. Proposed National Water Resource Strategy 2 [NWRS 2]: Summary: Managing Water for an Equitable and Sustainable Future: Summary July 2012. p.41.

67 Turton, A. 2008. op. cit.

68 Republic of South Africa. 1998. op. cit.

69 Binns, J.A., Illgner, P.M. and Nel, E.L. 2001. op. cit.

70 Republic of South Africa. 1998. op. cit.

71 Ibid.

72 Department of Water Affairs. 2012a. op. cit.

73 Quinn, C.H., Ziervogel, G., Taylor, A. and Thomalla, F. 2011. Coping with multiple stresses in rural South Africa. Ecology and Society 16(3): 2. Available online: http://dx.doi.org/10.5751/ES-04216- 160302.

74 Feely, T., Skone, T., Stiegel, G., McNemar, A., Nemeth, M., Schimmoler, B., et al. 2008. Water footprint of bio-energy and other primary energy carriers. Energy 33: 1-11.

75 Department of Water Affairs. 2012a. op. cit.

76 Tapela, B.N. 2012. Social water scarcity and water use: Report to the Water Research Commission. WRC Report No. 1940/1/11. Available online: www.wrc.org.za.

77 Bhagwan, J. 2012. Press Release: Water scarcity – an unresolved issue in many parts of the country leads to protests over service delivery. Water Research Commission. Available online: http://www. wrc.org.za/News/Pages/Waterscarcity%E2%80%93anunresolvedissueinmanypartsofthecountryleadstoprotestsoverservicedelivery.aspx.

78 Molewa, E. 2012b. Press Release: Minister of Water Affairs: Collaboration is key in resolving water challenges around the country “Let’s approach the water challenges in our areas together”. 13 August 2012. Available online: http://www.dwaf.gov.za/Communications/PressReleases/2012/Collaboration%20is%20key%20in%20resolving%20water%20challenges%20around%20the%20country.pdf.

79 Tapela, B.N. 2012. op. cit. p.90.

80 Ibid. p.61.

81 Bhagwan, J. 2012. op. cit.

82 Lévite, H., Faysse, N. and Ardorino, F. 2003. Resolving water use conflicts through stakeholder participation: Issues and examples from the Steelpoort Basin in South Africa. African Water Journal: 32-45. Available online: http://new.uneca.org/Portals/3/documents/African_Water_Journal_rev.pdf.

83 Turton, A. 2008. op.cit.

84 WWF-SA. 2011. Coal and Water Futures in South Africa: The case for protecting headwaters in the Enkangala grasslands. Available online: http://assets.wwfza.panda.org.wwf-web-1.bluegecko.net/ downloads/wwf_coal_water_report_2011_web.pdf.

85 Wassung, N. 2010. op. cit.

86 Groenewald, Y. 2012. Coal’s hidden water cost to South Africa. Commissioned by Greenpeace Africa. Available online: http://www.greenpeace.org/africa/Global/africa/publications/coal/ CoalsHiddenWaterCost.pdf.

87 Intergovernmental Panel on Climate Change (IPCC). 2007. Fourth Assessment Report: Summary for Policymakers. United Nations Environment Programme. Available online: http://www.ipcc.ch/pdf/ assessment-report/ar4/wg1/ar4-wg1-spm.pdf.

88 Department of Water Affairs and Forestry. 2009. op. cit.

89 Ibid.

90 WWF-SA. 2011. op. cit.

91 Department of Water Affairs and Forestry. 2009. op. cit.

92 Boko, M., I. Niang, A. Nyong, C. Vogel, A. Githeko, M. Medany, B. Osman-Elasha, R. Tabo and P. Yanda, 2007: Africa. Climate Change 2007: Impacts, Adaptation and Vulnerability. Contribution of Working Group II to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change, M.L. Parry, O.F. Canziani, J.P. Palutikof, P.J. van der Linden and C.E. Hanson, Eds., Cambridge University Press, Cambridge UK, 433-467. p.448. Available online: http://www.ipcc.ch/publications_and_data/ar4/wg2/en/ch9.html.

93 WWF-SA. 2011. op. cit.

94 Eberhard, A. 2011.op. cit.

95 Eskom Holdings Limited. 2011a. op. cit. p.44.

96 International Energy Agency (IEA). 2011. op. cit. and Eskom Holdings Limited. 2011b. op. cit.

97 Eskom Holdings Limited. 2011a. op. cit. p.44.

98 International Energy Agency (IEA). 2011. op. cit.

99 Eskom Holdings Limited. 2012. New Build Programme. Available online: http://www.eskom.co.za/c/article/53/new-build-programme/.

100 EIA. 2008. Country Analysis Briefs: South Africa. Available online: http://www.eia.gov/emeu/cabs/South_Africa/pdf.pdf

101 Tait, L. and Winkler, H. 2012. Estimating greenhouse gas emissions associated with achieving universal access to electricity in South Africa. Energy Research Centre, University of Cape Town. Available online: http://www.erc.uct.ac.za/Research/publications/12Tait-Winkler-Emissions.pdf.

102 Tait, L. and Winkler, H. 2012. op. cit.

103 Department of Government Communications and Information System. 2010. South Africa Yearbook 2010/2011: Chapter 8: Energy. Available online: http://www.gcis.gov.za/sites/default/files/docs/ resourcecentre/yearbook/chapter8.pdf.

104 Groenewald, Y. 2012. op. cit.

105 Eberhard, A. 2011. op. cit.

106 Greenpeace and the European Renewable Energy Council. 2011. op. cit.

107 Eskom Holdings Limited. 2008. Map of Eskom power stations. Available online: http://www.eskom.co.za/c/article/730/map-of-eskom-power-stations/.

108 Department of Energy. 2010. South African Energy Synopsis 2010. Available online: http://www.energy.gov.za/files/media/explained/2010/South_African_Energy_Synopsis_2010.pdf.

109 Eberhard, A. 2011. op. cit.

110 Ibid.

111 Eskom Holdings Limited. 2011b. Eskom Integrated Report 2011. p. 96. Available online: http://financialresults.co.za/2011/eskom_ar2011/index.php.

112 Eskom Holdings Limited. 2012. Kusile Power Station. Available online: http://www.eskom.co.za/c/article/58/kusile-power-station/.

113 Eberhard, A. 2011. op. cit.

114 Munnik, V., Hochmann, G., Hlabane, M. and Law, S. 2010. The Social and Environmental Consequences of Coal Mining in South Africa: A CASE STUDY. Environmental Monitoring Group and Both ENDs. Available: http://www.woek.de/web/cms/upload/pdf/kasa/publikationen/munnik_2010_the_social_and_environmental_consequences_of_coal_mining_in_sa.pdf.

115 Eberhard, A. 2011. op. cit.

116 Shuster, E., McNemar, A., Stiegal, G.J. and Murphy, J. 2007. Estimating Freshwater Needs to Meet Future Thermoelectic Generation Requirements, 2007 Update: DOE/NETL-400/2007/1304. National Energy Technology Laboratories. Available online: http://www.fypower.org/pdf/DOE_WaterNeedsAnalysis_2007.pdf.

117 Greenpeace International. 2008a. False Hope: Why carbon capture and storage won’t save the climate: p.6. Available online: http://www.greenpeace.org/international/Global/international/planet-2/ report/2008/5/false-hope.pdf.

Water hungry coal: Burning South Africa’s water to produce electricity 35 118 Inglesi-Lotz, R. and Blignaut, J. 2011. op. cit. p.88.

119 Von Uexkull, O. 2004. op. cit.

120 Inglesi-Lotz, R. and Blignaut, J. 2011. op. cit. p.88.

121 Wassung, N. 2010. op. cit.

122 Department of Energy. 2011. Integrated Resource Plan for Electricity, 2010- 2030. 2nd revision: March 25 2011. Available online: http://www.energy.gov.za/IRP/irp%20files/IRP2010_2030_Final_ Report_20110325.pdf.

123 Pressly, D. 2012. Gigaba moots more coal power. Business Report: 20 September 2012. Available online: http://www.iol.co.za/business/business-news/gigaba-moots-more-coal-power- 1.1386934#comments_start.

124 McCarthy, T.S. and Pretorius, J.P. 2009. Coal mining on the Highveld and its implications for future water quality in the Vaal River System. Working Paper, School of Geosciences, University of Witwatersrand. Available online: http://www.imwa.info/docs/imwa_2009/IMWA2009_McCarthy.pdf.

125 Eberhard, A. 2011. op. cit.

126 Wassung, N. 2010. op. cit.

127 Riekert, J. 2011. The health costs of coal-fired power generation in South Africa, p.34 in Blignaut, J. et al. 2011. Business Enterprises: University of Pretoria: unpublished research paper.

128 Wassung, N. 2010. op. cit.

129 Department of Energy. 2011. op. cit.

130 Wassung, N. 2010. op. cit.

131 Department of Water Affairs and Forestry. 2004. op. cit.

132 Wassung, N. 2010. op. cit.

133 Department of Water Affairs and Forestry. 2009. op. cit.

134 Department of Water Affairs and Forestry. 2004. op. cit.

135 Department of Water Affairs and Forestry. 2004. op. cit.

136 Eskom Holdings Limited. 2011a. op. cit. p.5.

137 Department of Water Affairs and Forestry. 2004. op. cit.

138 Wassung, N. 2010. op. cit.

139 Ibid.

140 African National Congress (ANC). 2012. op. cit.

141 Blignaut, J., Nkambule, N., Riekert, J. and Inglesi-Lotz, R. 2011. Coal and coal-fired generation in South Africa, p.27 in Blignaut, J. et al. 2011. The external cost of coal-fired power generation: the case of Kusile. Business Enterprises: University of Pretoria: unpublished research paper.

142 National Planning Commission. 2012. Our future – make it work: National Development Plan 2030. Available online: http://www.info.gov.za/issues/national-development-plan/index.html.

143 Wassung, N. 2010. op. cit.

144 Turton, A. 2008. op.cit.

145 Greenpeace and the European Renewable Energy Council. 2011. op. cit.

146 Ibid.

147 Global Wind Energy Council. 2011. Global Wind Report – Annual Market Update 2010. Available online: http://gwec.net/wp-content/uploads/2012/06/GWEC_annual_market_update_2010_-_2nd_ edition_April_2011.pdf.

148 European Photovoltaic Industry Association and Greenpeace International. 2011. Solargeneration 6 – solar photovoltaic electricity empowering the world. Available online: http://www.epia.org/ publications/epiapublications/solar-generation-6.html.

149 Wassung, N. 2010. op. cit.

150 Greenpeace International. 2008b. The True Cost of Coal: How people and the planet are paying the price for the world’s dirtiest fuel. Available online: http://www.greenpeace.org/international/en/ publications/reports/true-cost-coal/.

151 Nkambule, N. and Blignaut, J. 2011. The external costs of coal mining: the case of collieries supplying Kusile power station, p.110 in Blignaut, J. et al. 2011. The external cost of coal-fired power generation: the case of Kusile. Business Enterprises: University of Pretoria: unpublished research paper.

152 Wassung, N. 2010. op. cit.

153 Nkambule, N. and Blignaut, J. 2011. op. cit. p.122.

154 Ibid. p.122.

155 Wassung, N. 2010. op. cit.

156 Greenpeace International. 2008b. op. cit.

157 Nkambule, N. and Blignaut, J. 2011. op. cit. p.110.

158 Wilson, W., Leipzig, T. and Griffiths-Sattenspiel. 2012. op. cit.

159 Wassung, N. 2010. op. cit.

160 Ibid.

161 Ibid.

162 Ibid.

163 Ibid. p.18.

164 Ibid.

165 Wilson, W., Leipzig, T. and Griffiths-Sattenspiel. 2012. op. cit.

166 Wassung, N. 2010. op. cit.

167 Eskom Holdings Limited. 2011a. op. cit. p.64.

168 Wassung, N. 2010. op. cit.

169 Eskom Holdings Limited. 2012. op. cit.

170 Potgieter, P. H. 2010. op. cit.

171 Eberhard, A. 2011. op. cit.

172 Munnik, V., Hochmann, G., Hlabane, M. and Law, S. 2010. op. cit.

173 Department of Water Affairs and Forestry. 2009. op. cit.

174 Department of Water Affairs and Forestry. 2009. op. cit.

175 Molewa, E. 2012a. op. cit.

176 WWF-SA. 2011. op. cit.

177 Bell, F., Halbich, T. and Bullock, S. 2001. The effects of acid mine drainage from an old mine in the Witbank Coalfield, South Africa. Quarterly Journal of Engineering Geology and Hydrogeology, 35(3): 265-278.

178 Department of Mineral Resources. 2012. Operating Mines Excel List. Available online: http://www.dmr.gov.za/publications/viewdownload/121/762.html.

179 WWF-SA. 2011. op. cit.

36 Water hungry coal: Burning South Africa’s water to produce electricity 180 Parliamentary Monitoring Group. 2010. Auditor-General Performance Audit Report on Rehabilitation of Abandoned Mines. 31 August 2010. Available online: http://www.pmg.org.za/report/20100901- auditor-generals-performance-audit-rehabilitation-abondoned-mines-dep.

181 Blaine, S. 2012. No mine rehabilitation plan: 17 September 2012. Business Day. Available online: http://www.bdlive.co.za/national/science/2012/09/17/no-mine-rehabilitation-plan.

182 Bell, F., Halbich, T. and Bullock, S. 2001. op. cit.

183 Munnik, V., Hochmann, G., Hlabane, M. and Law, S. 2010. op. cit.

184 Miningmx. 2010. Abandoned mines poison SA water, 01 September 2010. Available online: http://www.miningmx.com/news/markets/Abandoned-mines-poison-SA-water.htm.

185 Munnik, V., Hochmann, G., Hlabane, M. and Law, S. 2010. op. cit.

186 Munnik, V., Hochmann, G., Hlabane, M. and Law, S. 2010. op. cit.

187 Department of Water Affairs. 2012b. Feasibility study for a Long-Term Solution to address the Acid Mine Drainage associated with the East, Central and West Rand Underground Mining Basins, Gauteng Province. AMD FS LTS Newsletter. Edition One: July 2012. Available online: http://www.dwaf.gov.za/Projects/AMDFSLTS/Documents/AMD%20FS%20LTS_Newsletter%2001%20%28Low%20Resolution%20 -%204MB%29.pdf.

188 Eberhard, A. 2011. op. cit.

189 WWF-SA. 2011. op. cit.

190 Eberhard, A. 2011. op. cit.

191 Ashton, P., Mahachi, H. and Dirks, P. 2001. An overview of the impact of mining and mineral processing operations on water resources and water quality in the Zambezi, Limpopo and Olifants catchments in Southern Africa. Mining, Minerals and Sustainable Development Project, Southern Africa. Available online: http://pubs.iied.org/pdfs/G00599.pdf.

192 WWF-SA. 2011. op. cit.

193 Sarmiento, A.M., Olias, M., Nieto, J.M., Canovas, C.R. and Delgado, J. 2009. Natural attenuation processes in two water reservoirs receiving acid mine drainage. The Science of the Total Environment 407: 2051-2062.

194 Penreath, R.J. 1994. The discharge of waters from active and abandoned mines. In: Hester, R.E. & Harrison, R.M. (eds.) Mining and its environmental impact. Issues in Environmental Science and Technology no. 1. Royal Society of Chemistry, Herts, UK. p.121-132.

195 WWF-SA. 2011. op. cit.

196 Eberhard, A. 2011. op. cit.

197 WWF-SA. 2011. op. cit.

198 Department of Water Affairs and Forestry. 2009. op. cit.

199 Department of Water Affairs. 2012b. op. cit.

200 Munnik, V., Hochmann, G., Hlabane, M. and Law, S. 2010. op. cit.

201 WWF-SA. 2011. op. cit.

202 Munnik, V., Hochmann, G., Hlabane, M. and Law, S. 2010. op. cit.

203 Eberhard, A. 2011. op. cit.

204 Van Wyk, J.J., Rademeyer, J.I. and van Rooyen, J.A. 2010. Department of Water Affairs: Position statement on the Vaal River system and Acid Mine Drainage: November 2010. Available online: http:// www.dwaf.gov.za/Projects/AMDFSLTS/Documents/Vaal%20River%20System%20&%20AMD%20Version%203.pdf.

205 Ashton, P., Mahachi, H. and Dirks, P. 2001. op. cit.

206 WWF-SA. 2011. op. cit.

207 Ashton, P., Mahachi, H. and Dirks, P. 2001. op. cit.

208 Department of Water Affairs and Forestry. 2009. op. cit.

209 Munnik, V., Hochmann, G., Hlabane, M. and Law, S. 2010. op. cit.

210 Ibid.

211 Department of Water Affairs. 2012b. op. cit.

212 Engineering News. 2012. Water as crucial as coal – Eskom. 2 February 2012. Available online: http://www.tradeinvestsa.co.za/news/1159141.htm.

213 Eskom Holdings Limited. 2012. op. cit.

214 Eberhard, A. 2011. op. cit.

215 Eskom Holdings Limited. 2012. op. cit.

216 Ibid.

217 Ibid.

218 Ibid.

219 Blignaut, J., Koch, S., Riekert, J., Inglesi-Lotz, R. and Nkambule, N. 2011. op. cit. p.14.

220 Wassung, N. 2010. op. cit.

221 Eskom Holdings Limited. 2011a. op. cit.

222 Eskom Holdings Limited. 2012. op. cit.

223 Eskom Holdings Limited. 2012. op. cit.

224 Wassung, N. 2010. op. cit.

225 Eskom Holdings Limited. 2009. op. cit.

226 Eskom Holdings Limited. 2010. Eskom Annual Report 2010. Available online: http://www.eskom.co.za/annreport10.

227 Ninham Shand. 2007. Environmental Impact Assessment Process: Proposed coal-fired power station and associated infrastructure in the Witbank Area: Final Environmental Impact Report. Proposed coal fired power station in the Witbank area: EIR. Available online: http://www.eskom.co.za/content/final%20eir.pdf.

228 Riekert, J. 2011. op. cit. p. 37.

229 Ibid. p. 37.

230 Ibid. p. 38.

231 Greenpeace International. 2008a. op. cit.

232 Ibid.

233 World Business Council for Sustainable Development (WBCSD), 2006. Facts and Trends – Carbon Capture and Storage. Available online: http://www.wbcsd.org/web/publications/facts&trends-ccs.pdf.

234 Rubin, E. et al., 2005. Technical Summary in IPCC Special Report on Carbon Dioxide Capture and Storage, B. Metz et al., Editors. 2005, Cambridge University Press: Cambridge, U.K.

235 Greenpeace International. 2008a. op. cit.

236 Ibid. p.5.

237 Ibid. p.5.

238 Ibid. p.7.

239 Shuster, E., McNemar, A., Stiegal, G.J. and Murphy, J. 2007. op. cit.

240 Greenpeace International. 2008a. op. cit. p.26.

241 Greenpeace International. 2008a. op. cit.

242 Blignaut, J., Nkambule, N., Riekert, J. and Inglesi-Lotz, R. 2011. op. cit. p.27.

Water hungry coal: Burning South Africa’s water to produce electricity 37 243 Singleton, T.C. 2010. The decision to install flue gas desulphurization on Medupi power station: identification of environmental criteria contributing to the decision making process. Research report, Master of Science in Engineering degree, University of the Witwatersrand, South Africa. Available online: http://wiredspace.wits.ac.za/bitstream/handle/10539/8387/Tyrone%20C%20Singleton_9601499FINAL. pdf?sequence=1.

244 Singleton, T.C. 2010. op. cit.

245 Eskom Holdings Limited. 2012. op. cit.

246 Singleton, T.C. 2010. op. cit.

247 Eskom Holdings Limited. 2011a. op. cit.

248 Singleton, T.C. 2010. op. cit.

249 Inglesi-Lotz, R. and Blignaut, J. 2011. op. cit. p.88.

250 Department of Water Affairs. 2012a. op. cit.

251 Eskom Holdings Limited. 2011a. op. cit. p.4.

252 Groenewald, Y. 2012. op. cit.

253 Department of Water Affairs. 2012a. op. cit.

254 Wassung, N. 2010. op. cit.

255 Department of Water Affairs. 2012a. op. cit.

256 Wassung, N. 2010. op. cit.

257 Spalding-Fetcher, R. and Matibe, D. 2003. Electricity and externalities in South Africa. Energy Policy, 31: 721-734.

258 Department of Water Affairs and Forestry. 2009. op. cit.

259 Wassung, N. 2010. op. cit. p.11.

260 Wassung, N. 2010. op. cit.

261 Eskom Holdings Limited. 2012. op. cit.

262 Wassung, N. 2010. op. cit.

263 Ibid.

264 Republic of South Africa. 1998. op. cit.

265 Ninham Shand. 2007. op. cit.

266 Ibid.

267 Department of Water Affairs. 2012b. op. cit.

268 Van Wyk, J.J., Rademeyer, J.I. and van Rooyen, J.A. 2010. op. cit.

269 Ninham Shand. 2007. op. cit.

270 Eberhard, A. 2011. op. cit.

271 Ninham Shand. 2007. op. cit.

272 Eskom Holdings Limited. 2012. op. cit.

273 Department of Water Affairs and Forestry. 2009. op. cit.

274 Department of Water Affairs. 2012a. op. cit.

275 Ibid.

276 Von Uexkull, O. 2004. op. cit.

277 Department of Water Affairs and Forestry. 2009. op. cit. p.27.

278 Department of Water Affairs and Forestry. 2009. op. cit.

279 Eskom Holdings Limited. 2012. op. cit.

280 Blignaut, J., Koch, S., Riekert, J., Inglesi-Lotz, R. and Nkambule, N. 2011. op. cit. p.14.

281 Eskom Holdings Limited. 2012. op. cit.

282 Ibid.

283 World Bank. 2010. Project Appraisal document on a proposed loan in the amount of US$3,750 million to Eskom Holdings Limited guaranteed by Republic of South Africa for an Eskom investment support project: Report No: 53425-ZA. Energy Group: Sustainable Development Department, Africa Region. Available online: http://siteresources.worldbank.org/PROJECTS/ Resources/40940-1097257794915/537867-1136835492035/SouthAf-Eskom-PAD.pdf.

284 Von Uexkull, O. 2004. op. cit.

285 Wassung, N. 2010. op. cit.

286 Engineering News. 2010. Renewables, imports to feature strongly in new SA energy plan. Available online: http://www.engineeringnews.co.za/article/renewables-imports-to-feature-strongly-in-new-sa- energy-plan-2010-04-06.

287 Von Uexkull, O. 2004. op. cit.

288 Wassung, N. 2010. op. cit.

289 Inglesi-Lotz, R. and Blignaut, J. 2011. op. cit. p.88.

290 Ibid.

291 Blignaut, J., Koch, S., Riekert, J., Inglesi-Lotz, R. and Nkambule, N. 2011. op. cit. p.18.

292 Greenpeace and the European Renewable Energy Council. 2011. op. cit.

293 Ibid.

294 Von Uexkull, O. 2004. op. cit.

295 Wassung, N. 2010. op. cit.

296 Department of Water Affairs and Forestry. 2009. op. cit.

297 Republic of South Africa. 1998. op. cit.

298 Department of Water Affairs. 2012a. op. cit.

299 Republic of South Africa. 1998. op. cit.

300 Wassung, N. 2010. op. cit.

301 Ibid.

302 Turton, A. 2008. op.cit.

303 Ibid.

304 Ibid.

305 Wassung, N. 2010. op.cit.

306 Department of Water Affairs and Forestry. 2009. op.cit.

38 Water hungry coal: Burning South Africa’s water to produce electricity

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